Cedar Lane Technologies Inc. v. Safra Securities LLC

I'll research this case and its context before drafting the overview.

Case Overview & Background

Parties and their business. Cedar Lane Technologies Inc. is a Canadian patent-holding entity (recorded assignee address: Canada, per the USPTO assignment on the face of the patent) — a classic non-practicing entity/PAE with no operating business in electronic trading. Cedar Lane is a well-known serial plaintiff: its earlier campaigns asserted media/software patents acquired from AVInnov and Intellectual Ventures (e.g., U.S. 7,173,177, covering playlist ownership indicators, asserted against Charter, T-Mobile, Disney, Dish and CBS, and later invalidated in Unified Patents v. Cedar Lane, IPR2020-00006, Final Written Decision Feb. 12, 2021 — https://www.unifiedpatents.com/insights/2021/2/12/cedar-lane-patent-held-unpatentable). The Safra suit is part of a distinct, more recent Cedar Lane campaign in financial trading technology, handled by Isaac Rabicoff of Rabicoff Law LLC (Chicago), a high-volume patent plaintiff's firm (Dkt. 6, PHV motion filed 11/14/2025). Defendant Safra Securities LLC is a New York broker-dealer; the complaint itself does not describe Safra's business in detail, and I was not able to independently verify Safra's corporate affiliation or ownership from the sources retrieved here — public descriptions commonly place the "Safra Securities" name within the Safra banking family (J. Safra group), but treat that as unconfirmed. Safra retained Locke Lord LLP (Scott David Wofsy), whose notice of appearance was filed January 21, 2026 (Dkt. 16).

The accused technology. U.S. Patent No. 8,577,782, "Trading with conditional offers for semi-anonymous participants," issued November 5, 2013 on an application filed April 8, 2010, naming Christopher R. Petruzzi (San Clemente, CA) as inventor, classified in G06Q 40/00 and U.S. class 705/37 (trading/matching/bidding); estimated expiry April 8, 2030 (https://patents.google.com/patent/US8577782; https://patents.justia.com/patent/8577782). One-line technical sketch: it claims a method in which a trading "Taker" is associated with a persistent but non-identifying identifier, a liquidity provider acquires that taker's trade history through the exchange, builds a "profile" indicating whether the taker's past trades would have been profitable (i.e., whether the taker is "toxic" or "naive"), and then generates a conditional bid/ask offer that may only be accepted by that specific taker — letting market makers price-discriminate in an otherwise anonymous market. Claim 1 requires "a processor implemented at least partly in hardware," and the family includes at least one later continuation publication (US 20230281711A1), meaning additional claim sets remain available. The value proposition in the specification is expressly risk management/fraud-adjacent: protecting market makers from informed traders while offering better prices to uninformed ones. Consistently with the pattern across the campaign, Cedar Lane's five-page complaint asserted "one or more" claims by reference to "Exemplary '782 Patent Claims" and an Exhibit 2 claim chart (Dkt. 1), rather than pleading a specific accused product by name or a specific asserted claim in the body — a point noted critically in analyses of the parallel complaints (e.g., https://ai-lab.exparte.com/case/dct/txed/2:25-cv-01225/doc/analysis/1). Practically, the "accused product" is Safra's electronic brokerage/trading order-handling and execution platform, but the operative detail sits in the claim chart rather than the pleadings.

Procedural posture, venue, and why it matters. Cedar Lane filed in S.D.N.Y. on November 14, 2025, and the case was assigned to Judge John P. Cronan (Dkt. 1; https://cdn.pacermonitor.com/public/case/61196849/). Service was effected December 17, 2025, prompting a January 9, 2026 order (Dkt. 11); Safra obtained a consent extension to answer to March 2, 2026 (Dkt. 14, Jan. 16, 2026); Cedar Lane then filed a Rule 41(a)(1)(A)(i) notice of voluntary dismissal without prejudice on January 30, 2026 (Dkt. 17), which Judge Cronan so-ordered on February 2, 2026 (Dkt. 19). No answer, motion to dismiss, claim construction, or merits ruling ever issued — Safra's answer was due a month after the case ended. S.D.N.Y. mattered here for two reasons: (i) it is the natural forum for New York broker-dealers under the patent venue statute, and after TC Heartland plaintiffs suing financial institutions have increasingly filed where the defendant actually has an established place of business rather than defaulting to E.D. Tex./W.D. Tex.; and (ii) Cedar Lane was running a coordinated multi-forum wave — the same week's S.D.N.Y. filings against BNY Mellon (1:25-cv-09488, filed 11/13), First Manhattan Securities (1:25-cv-09485), Empire Asset Management (1:25-cv-09526), Percheron (1:25-cv-09531) and Spartan Capital (1:25-cv-09535), alongside E.D. Tex. and later W.D. Tex./N.D. Ill./E.D.N.Y. suits (Stanford NPE Litigation Database, https://npe.law.stanford.edu/patent/8577782).

Why the case is notable. First, it is part of an unusually broad, single-patent assertion wave against the retail brokerage and banking sector — Cedar Lane has sued, on the '782 patent alone, Bank of America, Citibank, Morgan Stanley, Raymond James, BNY Mellon, TD Bank, Cantor Fitzgerald, BTG Pactual, Firstrade, Cobra Trading, Lion Street, Prosperum, David Lerner, Horace Mann, Ameritas and others beginning in February 2025 (https://npe.law.stanford.edu/patent/8577782; Law360, Sept. 23, 2025, noting suits against Citibank and Cantor Fitzgerald over "a trading patent," https://www.law360.com/cases/68d18141275816cbcd389330). Second, it illustrates the modern file-and-settle NPE playbook with striking efficiency: this case lasted 80 days, and sibling suits resolved equally fast — BNY Mellon and First Manhattan were dismissed with prejudice (Jan. 30 and Dec. 30, 2025), David Lerner settled, and Firstrade dismissed without prejudice 61 days after filing. Third, there is no identified IPR or other PTAB challenge to the '782 patent in the sources reviewed — so its claims have never been tested for validity, and no defendant has yet obtained a merits ruling; the patent's § 101 exposure (it is a 2010-priority business-method claim in class 705) and its "at least partly in hardware" limitation are the obvious vulnerability that a well-funded defendant could exploit, but no one in this campaign appears to have done so. Fourth, the campaign is a useful marker of PAE venue migration in fintech: filings track where the defendant banks are actually located, and the low per-case investment (5-page complaints, claim charts attached as exhibits, PHV admission for a single out-of-state plaintiff's lawyer) is calibrated for quick nuisance-value settlements. Finally, the case is a data point in the broader scrutiny of Rabicoff Law's filing practices — Rabicoff was sanctioned and referred to the N.D. Cal. Standing Committee on Professional Conduct in 2020 in Cedar Lane v. Blackmagic Design for serial filing and pro hac vice avoidance (https://cases.justia.com/federal/district-courts/nevada/nvdce/3:2025cv103/[173189](/patent/173189)/37/0.pdf), which is relevant context for the compliance posture of this campaign, though nothing in the Safra docket itself reflects any such issue and Rabicoff did file a PHV motion here (Dkt. 6).

Sourcing note: the docket entries, dates, counsel and dismissal terms above are drawn from PACER-derived aggregators (Justia, PacerMonitor) and match across sources; the patent text/claims and prosecution data are from Google Patents/Justia Patents. Certain facts — Safra Securities' corporate affiliation, the specific claim(s) and product(s) charted in Exhibit 2, and any settlement/license consideration behind the dismissal — are not publicly documented in what I could retrieve and should be treated as unverified.

I'll research this case and its related proceedings.

I'll research the counsel of record for Cedar Lane Technologies in this case.

Counsel of Record for Plaintiff Cedar Lane Technologies Inc.

Bottom line: one attorney appeared for the plaintiff — Isaac P. Rabicoff of Rabicoff Law LLC (Chicago). No local counsel, no co-counsel, and no in-house counsel entered an appearance in this 80-day case.

Isaac Phillip Rabicoff — sole counsel; lead counsel (admitted pro hac vice)

Relevant patent litigation experience (as publicly reported):

• Registered patent attorney (B.S. Physics, Kansas; J.D. Loyola-Chicago) admitted in Illinois and Virginia, before the Federal Circuit and Seventh Circuit; founder of Rabicoff Law, which his firm bio says was among Lex Machina's top-3 most active patent litigation firms in 2017, and which has led licensing campaigns against Amazon, Microsoft, Sony, Apple, LG, Huawei, Samsung and Google (firm bio).
• He is Cedar Lane's near-exclusive outside counsel — by far the dominant filer of Cedar Lane's suits (58 Cedar Lane cases as of a 2022 Chinese IP-center study; Law360 currently lists ~1,469 docket appearances for him), including the same-day wave of § 271 suits against broker-dealers in S.D.N.Y. in November 2025 (e.g., Nos. 1:25-cv-09485, -09488, -09526, -09529, -09531, -09535, -09538), all filed with him as sole counsel.
• PTAB experience: his bio credits him with defeating institution of numerous IPRs/CBMs, including denial of institution on all claims in a CBM petition filed by Mastercard, and he has argued before the Federal Circuit.
• Adverse history worth flagging: In Cedar Lane Techs. Inc. v. Blackmagic Design Inc., No. 20-cv-01302-VC (N.D. Cal. Nov. 19, 2020), Judge Chhabria sanctioned Rabicoff $1,000 under Rule 11 and the court's inherent authority, referred him to the N.D. Cal. Standing Committee on Professional Conduct for serial pro hac vice practices, and denied his pro hac vice motion; the Standing Committee's 2022 informal resolution required him to pay $9,193 in past PHV fees (In re Isaac Rabicoff, No. 20-mc-80206-JD). The Illinois ARDC closed its related file in July 2022 while expressing concern about Rule 5.5(a) compliance. This history resurfaces in later opinions, e.g., the Nevada decision at cases.justia.com (3:25-cv-00103, Dkt. 37).

Attorneys who did not appear

• No local counsel: S.D.N.Y. permits pro hac vice admission without a local sponsor, and Rabicoff proceeded alone; no other attorney ever filed a notice of appearance for Cedar Lane (contrast defendant Safra Securities, which appeared through Scott David Wofsy of Locke Lord LLP, Dkt. 16).
• No in-house counsel: Cedar Lane's principal, Greg Benoit (a lawyer and director/president of the Canadian entity), did not enter an appearance; the Rule 7.1 statement (Dkt. 3) lists no corporate parent.
• No filings in this docket are sealed; the file is complete and publicly available, so the absence of additional plaintiff counsel is a reliable conclusion rather than an artifact of sealing. One caveat: the full text of Rabicoff's PHV affidavit (Dkt. 6-1) is not reproduced in the free aggregators I could access, so I cannot confirm whether it names any additional firm affiliation beyond Rabicoff Law LLC.

Case-specific role note: Rabicoff's only substantive activity was service-related (Dkts. 11–12, 15) and a consent extension of Safra's answer deadline to 2 March 2026 (Dkt. 13), before he filed the Rule 41(a)(1)(A)(i) voluntary dismissal on 30 Jan 2026 (Dkt. 17), granted 2 Feb 2026 (Dkt. 19) — consistent with Cedar Lane's documented pattern of rapid file-and-settle campaigns.

I'll research the docket and counsel appearances for this case.

I have the key docket entry. Let me dig into the counsel details.

Let me verify the full docket and check for any additional appearances or related representation.